v  To be successful, India’s APA program need to provide an atmosphere in which all parties can come to the table intending to find a mutually satisfactory arrangement.

v  The APA scheme has many advantages. It will provide tax certainty with regard to determination of arm’s length price of the international transaction with respect to which the APA has been entered into, reduce the risk of potential double taxation through bilateral or multilateral APA, reduce compliance cost by eliminating the risk of transfer pricing audit and resolving long drawn and time consuming litigation and other dispute resolution process and alleviate the burden of record keeping as the taxpayer knows in advance the required documentation to be maintained to substantiate the agreed terms and conditions of the agreement.

v  Introduction of the APA legislation would bring about certainty, clarity of opinion and other benefits to corporate India. So, it is high time India took a stride in this arena.

Regards , CA Sachin Jain